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Ayodhya and India's Mahabharat

Ayodhya and India


Ayodhya and India’s Mahabharat

Constitutional Issues and Proprieties

Ayodhya: 6 December 1992

by P V Narasimha Rao; Penguin India, 2006; pp 336, Rs 395.


V Narasimha Rao was the prime minister (PM) when India’s secular foundations were shaken by the wanton demolition of the Babri masjid. The ensuing communal holocaust led to 2,026 persons being killed and 6,957 injured, widened the communal divide and left visible scars of communal bitterness and hatred. Since this was one of the most shocking events in the history of independent India, it was expected that Rao’s book Ayodhya: 6 December 1992 would shed new light on the relevant issues. These expectations were reinforced since Rao wanted the book to be published only after his death. The book has belied these expectations.

After the first world war, a French general is stated to have written a glowing account of how well his troops had fought and won a battle in which their forces had actually suffered an ignominious defeat. The general gave the account to his second-incommand and asked him to dispatch it to the army headquarters. The next day the general asked him whether he had done so. The officer said, “Sir, I have not sent it since the account which you have written is quite the opposite of what actually happened”. The general coolly told him, “Ami, c’est pour l’ histoire” (friend, it is for history). The same can be said of Rao’s book.

Far from the TruthFar from the TruthFar from the TruthFar from the TruthFar from the Truth

Rao’s version of the events has come more than 13 years after the catastrophic event. According to the publisher’s note, Rao wrote this account after he stepped down as PM in 1996 and made revisions to the manuscript till a few days before his death in December 2004. Since Rao has so little to add to what was already contained in the central government’s ‘White Paper on Ayodhya’ (1993), it is not clear why he wanted to have it published only after his death. Was he afraid of people questioning him closely and joining issues with him?

Rao has stated, “I held a large number of meetings with individuals and groups directly concerned with the dispute, as well as journalists, political, religious and social leaders” (p 95). These discussions are stated to have “facilitated a better understanding of the position of the parties concerned and enabled various sections of them to put forward their own insights into the various facets of the problem (p 96). Rao has stated, “No specific proposal or suggestion for a solution was put forward on behalf of the government”. The book is silent on what transpired in these countless meetings in which only Rao had participated.

The book sheds no light on the decisionmaking process in government. When a prime minister writes an account of a unique historical event, it is not unreasonable to expect that he would elucidate the discussions which took place at the official and political levels and the considerations which weighed with him in taking the decisions. This is more so since, according to Rao, not taking a decision was also a decision! Rao claims, “the officers told me again and again that whatever was being done for queering the pitch was for political reasons and not based on what obtained on the field. They said they had studied the field and were quite clear that the ‘kar seva’ would be peaceful. This was the situation” (p 185). This was true only in respect of some officers. His assertion that, “today’s hindsight was not available to anyone in the government of India on those dates...The formidable snag is that no one at that crucial time knew how it was going to happen” (emphasis in the original) (p 171), is also far from true. While none could have precisely known “how it was going to happen”, there were serious apprehensions of the forthcoming calamity among some of Rao’s cabinet colleagues and some senior officers. This has been fully brought out in the memoirs of this author who was then the union home secretary [Godbole 1996].


We shall now turn to the discussion of the constitutional issues and proprieties on which Rao has rested his self-defence. The constitutional provisions for dealing with states which are remiss in fulfilling their constitutional obligations are the Articles 256, 355, 356 and 365, aptly described as New Delhi’s Long Arm [Austin 1999]. We shall examine the extent to which recourse to these could have been and was actually taken by the Rao government. Article 256 states, “The executive power of every state shall be so exercised as to ensure compliance with the laws made by Parliament and any existing laws which apply in that state and the executive power of the Union shall extend to the giving of such directions to a state as may appear to the government of India to be necessary for that purpose.” This article has been rarely invoked by the centre. Attention of the states of Kerala and West Bengal was, however, invited to the provisions of this article in 1968 when these states had declined to deal firmly with the central government employees’ strike and give adequate protection to the central government offices and public sector undertakings. In the agitation leading to the demolition of the Babri masjid, no formal directions were issued to the government of Uttar Pradesh (GoUP) but scores of letters, faxes and telephonic messages were sent to the state government at the level of union home minister and senior officers to urge that adequate precautions

Economic and Political Weekly May 27, 2006

should be taken to protect the disputed structure. These communications served the same purpose as directions under Article 256. It must be noted that issuing a direction under Article 256 implies that if it is contravened, it can lead to the dismissal of the state government and imposition of President’s Rule as provided in Article 365. In the explosive situation prevailing in UP, issuing a formal direction would have alerted the state government of the possible action under Article 356 and this could have been used as a pretext by kar sevaks and the ruling party activists to bring about the demolition of the masjid. The BJP could have then blamed the central government for it, as Kalyan Singh, chief minister, had been repeatedly threatening to do. Thus, in the extraordinary situation in UP, the use of Article 256 had its own limitations and could have been counterproductive.

It is important to understand the extent to which Article 355 could have come handy in dealing with the situation. Article 355 states that “It shall be the duty of the union to protect every state against external aggression and internal disturbance and to ensure that the government of every state is carried on in accordance with the provisions of this Constitution”. Noorani has commented that “Article 355 was not entirely born in sin, but was conceived in murky circumstances”, mainly to protect the thrones of princely rulers who wanted the union’s protection lest neighbouring provinces of the former British India or their own people rose in revolt in the altered circumstances [Noorani 2000]. As compared to similar provisions in the constitutions of the US and Australia, the provision in Article 355 does not contain a requirement of a request from the state government for protection and intervention by the centre. It is, however, important to note that the US Supreme Court has, as far back as in 1895, held that if internal disturbance in any state interfered with the operation of the national government itself or with the movement of interstate commerce, the centre can send force on its own initiative, without waiting for application from the state authorities. After this ruling, the requirement of an application by the affected state for aid for suppression of internal violence has lost its importance. In 1963, the US federal government did not hesitate to deploy the national militia in Little Rock to quell racial disturbances, and to enforce the decision of the supreme court on racial integration. This was done very much against the wishes of the state government [Jain 2005].

Misleading StatementsMisleading StatementsMisleading StatementsMisleading StatementsMisleading Statements

The term “internal disturbance” used in this article is much broader than the term “armed rebellion” used in Article 352 and can cover a wide variety of situations. The Sarkaria Commission has observed that, “the scope of the term ‘internal disturbance’ is wider than ‘domestic violence’. It conveys the sense of ‘domestic chaos’ which takes the colour of a security threat from its associate expression ‘external aggression’. Such a chaos could be due to various causes. Large-scale public disorder which throws out of gear the even tempo of administration and endangers the security of the state, is ordinarily, one such cause.” The commission also observed that “Article 355 not only imposes a duty on the union but also grants it, by necessary implication, the power of doing all such acts and employing such means as are essentially reasonably necessary for the effective performance of that duty” [GoI 1988]. The situation in UP leading to the demolition of the Babri masjid in 1992 was fully in keeping with the interpretation of the term “internal disturbance” given by the Sarkaria Commission.

Rao refers, at more than one place (pp 125, 151), to the contingency plan prepared by the central government to deal with the situation, but says that it was only to assist GoUP to deal with the situation effectively and “ensuring compliance with the orders of the court”. This is far from true. In fact, it is a travesty of the truth. Rao has himself stated that “As a measure of abundant caution, however, the central government had stationed 195 companies of central para military forces (CPMFs) near Ayodhya in November 1992 so that these could be made available at short notice if and when required by the state government or for any other contingent purpose” (emphasis added) (p 125). But, Rao has deliberately kept silent about the other contingent purpose, namely, dismissal of GoUP and imposition of president’s rule. Rao has made much of the fact that “the central government did not have even a toe-hold anywhere in UP at the time. In the absence of such a hold, the centre could not have found it feasible to take an extremely crucial step like the imposition of president’s rule in the teeth of determined resistance by an entrenched state government” (p 173). But, the comprehensive contingency plan prepared by the ministry of home affairs (MHA) was meant to deal with any such eventuality effectively and to ensure protection of the Babri masjid by swift action by commando units and paramilitary forces as a surprise move in the middle of the night, followed by imposition of president’s rule. The union home minister, in his reply to the marathon debate in the Lok Sabha on December 3, 1992, had clearly stated that “the centre could easily resort to Article 355 of the Constitution” (p 136). This was based on the contingency plan which the MHA had prepared. Since Rao did not want to take action under Article 356 coupled with a pre-emptive action under Article 355, the contingency plan became infructuous so far as the original objective was concerned.

The statement in the book that “it was not the position of the state government that they would not use the CPMFs even if it became necessary to do so” (p 141) is factually incorrect and misleading. The resolve of GoUP not to use CPMFs was amply evident by its refusal to deploy these forces in and near the masjid even though they were stationed in Faizabad and other nearby locations from November 24, 1992, the deliberate delay in calling the CPMFs on December 6 after the demolition of the structure began, and its refusal to provide magistrates to escort the CPMFs which led to their returning to the barracks. Further, since the GoUP had all along declared its intentions of not using force to deal with the kar sevaks, the CPMFs were not useful even as a show of force. As a result, the largest ever CPMF of about 20,000 men and women mobilised from all over the country and stationed just a few kilometres away from Ayodhya and other elaborate advance planning – procurement of rubber bullets, training of commando units, dog squads, bomb disposal squads, hundreds of requisitioned vehicles, water cannons, tonnes of concertina wire, firefighting equipment and vehicles – was of no use and the CPMFs had to watch helplessly when the structure was demolished. Rao prefers to keep this shocking reality away from the reader.

By the 42nd Amendment of the Constitution in 1975, a new Article 257A was added empowering the centre to deploy any central force for dealing with a grave situation of law and order in any state without its concurrence. Any such force was to act subject to the control and directions of the centre and not of the concerned state government. This provision

Economic and Political Weekly May 27, 2006 was deleted by the 44th Amendment due to the fears voiced by states, but Entry 2A still remains a part of the Union List. Even if Article 257A had continued to be a part of the Constitution, it would not have made any difference to the handling of the situation in UP since Rao government lacked the political will to act.

Non-invocation of Article 356Non-invocation of Article 356Non-invocation of Article 356Non-invocation of Article 356Non-invocation of Article 356

The third most potent instrument could have been Article 356 under which the state government could have been dismissed and president’s rule imposed. Rao has stated that “from millions of people has come the inevitable and irresistible question: Why did the president of India not impose president’s rule under Article 356 of the Constitution of India and save the structure in time?1 The central government certainly owes a full explanation to the people. It has been given several times, but it would be proper to consolidate the reply to the question in all its relevant aspects, to stand witness to history and throw light on the future” (sic) (p 166). Rao’s arguments for non-invocation of Article 356 are curious and hardly convincing. His assertion that “it was not possible to identify the stage, event or moment that could fit in the above description (i e, when it could be said that the government of the state could not be carried out according to the provisions of the Constitution) had not arisen” (p 169) is preposterous. This is amply borne out by the central government’s repeated pleadings before the Supreme Court – the solicitor general telling the court on November 24, 1992 that “the situation on the ground is escalating day by day” (p 111), the attorney general telling the court on November 25, 1992 that “the situation in Ayodhya had reached a boiling point” and warning that “even one day of adjournment could prove costly”. He had also told the court that the state government had clearly stated that “use of force to prevent kar seva will not be appropriate” (p 113). “The deficiencies in the existing security arrangements (made by GoUP) which were pointed out by the central government were taken note of by the court” (p 124). Rao has himself underlined that “the law and order implications of the Ram Janmabhoomi-Babri Masjid (RJB-BM) dispute had always been serious” (p 124). Rao has further admitted that “Based on past experience and the continuing undercurrent of communal tension on account of the RJB-BM dispute, serious apprehensions existed about the outbreak of fresh violence in various parts of the country, particularly if any untoward incident took place in Ayodhya during the proposed kar seva” (p 125). All this and much more evidence which was available with the centre was adequate to justify the dismissal of GoUP. But, Rao has asserted: “It is clear that on a correct construction of Article 356, it is not possible to invoke the provision to serve a preventive purpose in time. This is not a happy situation and calls for a relook at the language of Article 356, if it is to be provided with any legally valid “teeth” to serve a preventive purpose” (p 179). This too does not hold water as can be seen from the observations of Sawant and Kuldip Singh, JJ, in the Bommai case: “A reasonable prognosis of events to come and of their multifarious effects to follow can always be made on the basis of the events occurring, and if such prognosis led to the conclusion that in the circumstances, the governments of the states could not be carried out in accordance to the provisions of the Constitution, the inference cannot be faulted.”2 Equally relevant are the observations of Jeevan Reddy and Agrawal, J J, “The situation was an extraordinary one; its repercussions could not be foretold at that time. Nobody could say with definiteness what would happen and where? The situation was not only unpredictable, it was a fast evolving one. The communal situation was tense. It could explode anywhere at any time.”3 Though these observations were made by the court to uphold the dismissal of the governments of MP, HP and Rajasthan, they could have been made with even greater force to dismiss GoUP. And this is what MHA was repeatedly urging. The ministry of law had also concurred in the cabinet note prepared for the dismissal of GoUP.

On President’s RuleOn President’s RuleOn President’s RuleOn President’s RuleOn President’s Rule

Rao has claimed that he could not have taken action to impose president’s rule when the Supreme Court was holding hearings on almost day-to-day basis. However, the court itself had pointed out on November 25, 1992 that “the central government is, of course, at liberty to make its own assessment of the matter and take such action on its own as may appear to it proper and permissible” (p 115). It had declined to direct the central government to withdraw CPMFs from Ayodhya by saying, “neither of the court’s (previous) orders had prevented any constitutionally elected government from performing its duty in accordance with the law” (p 130). Rao’s argument that “the Supreme Court’s refusal even to make the central government a receiver (as pleaded by one of the

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Economic and Political Weekly May 27, 2006

petitioners) for the limited and specific purpose of giving adequate protection to the disputed structure at Ayodhya is also a meaningful pointer; it only translates into a ‘hands off the state’ directive to the centre” (p 180), is breathtaking. The fact that the central government did not even have a “toe-hold in UP” (words used by Rao at p 173) must have weighed with the court in not casting the responsibility of receivership on the centre. This author too had advised Rao that if the court appointed the central government as a receiver, such a responsibility could be discharged only if the state was taken under president’s rule.4 Rao’s self-serving and untenable interpretation of the Supreme Court’s position on receivership is a desperate attempt to justify his indecision and inaction.

Rao has made much of the advice given by the governor against imposition of president’s rule on the specious plea that “the governor is in charge of the state” (p 170). The governor is in charge of a state only when the state is under president’s rule. At other times, he is the constitutional head of a state. In the situation obtaining in UP and brought out, day after day, by the intelligence bureau reports to which Rao was a privy, it was abundantly clear that the governor had not kept himself informed of the rapidly deteriorating situation. It is nowhere laid down that the central government must go by the assessment of the governor. Article 356 clearly states, “If the president, on receipt of a report from the governor of a state or otherwise is satisfied...” (emphasis added). This was particularly so in the instant case. After the Babri masjid was demolished, the central government took the decision to dismiss not just GoUP, but also the BJP governments in MP, HP and Rajasthan to retrieve its secular credentials. This was in spite of the advice of MHA that the law and order situation in these states was much better than the Congress-ruled states of Maharashtra, Gujarat and Karnataka and these states were faithfully implementing central government orders, including action against banned organisations such as the RSS, VHP and Bajrang Dal. After taking the decision to dismiss these governments, the governors were told to send suitable reports for the purpose. So much for Rao’s avowed faith in constitutional proprieties!

In his speech in the constituent assembly, Ambedkar had hoped that “the proper thing we ought to expect is that such articles (emergency provisions) will never be called into operation and that they would remain a dead letter”. This hope was belied by the centre making blatant misuse, over the years, of Article 352 by declaration of emergency and of Article 356 by imposition of president’s rule in states on nearly hundred occasions. Against this background, it was supremely tragic that Article 356 remained a dead letter on perhaps the only occasion when its use would have made all the difference. Noorani has stated that in spite of the pious intentions of the founding fathers of the Constitution, “Article 356 is a weapon of first resort” (op cit, p 261). Unfortunately, in the instant case, it was not used even as an instrument of last resort. In fact, it was not used at all! Rao has referred to the judgment of the Supreme Court in the Bommai case for justifying his decision not to take recourse to Article 356. But, a close scrutiny of the judgment would show that none of the principles laid down by the court in that case would have been contravened if GoUP had been dismissed in November 1992. It may be pertinent to note that one of the very first cases of the use of Article 356 was the dismissal of Kerala government in 1959 on the ground of its failure to maintain law and order in the state. The same reasoning was used for dismissing some other state governments including the Tamil Nadu government in 1991. In all these cases, the gravity of the failure was much less as compared with the situation in UP in November 1992. Clearly, it was not the Constitution which was found wanting as averred by Rao. It was the failure of the national leadership during this critical period. In this light, Rao’s assertion that “any prudent president or prime minister would not have gone ahead and clamped Article 356 under these circumstances” (p 180) will not have many takers. A reference may also be made to Rao’s own observation that “Constitutional pundits, administrators and others understand that in some critical situations, time is of the essence in taking a decision” (p 181). Rao’s handling of RJB-BM dispute and its disastrous outcome proves its validity decisively.

A nagging question still remains. It is difficult to believe that Rao, who had spent a lifetime in national politics, was a close confidant and advisor of Indira Gandhi and Rajiv Gandhi, was a central minister for decades before he became prime minister, and was appropriately known as Chanakya, did not realise that it was imperative to take recourse to Articles 355 and 356 if the impending disaster was to be avoided. What then were his political compulsions for not doing so? Was he worried about the Hindu backlash if the Congress Party was seen to be opposing the construction of the Ram temple? Rao was well aware that, keeping in view of the importance of not alienating the Hindus, Rajiv Gandhi took the initiative to have the locks of the Ayodhya temple opened in 1986 and permitted “shilanyas” on the land in dispute in 1989. Rajiv Gandhi had also commenced his party’s election campaign in 1989 from Ayodhya promising to establish “Ram Rajya” [Gill 1996]. It is believed that in Rao’s wide-ranging confabulations, the fears of Hindu backlash were repeatedly voiced. Beneath the veneer of secularism of the Congress Party, there was a growing concern regarding the implications of opposing the Ayodhya agitation on the electoral fortunes of the party. When the centre’s strategy of kid-glove treatment of Ayodhya agitation failed and the masjid was demolished by kar sevaks leading to a severe backlash not just from the Muslims and secular sections, but even large sections of Hindus, the Congress Party made Rao the pariah and he was not even given a party ticket in the Lok Sabha election. It is perhaps in this sense that Rao has cryptically stated that, “They (his colleagues) were playing either for success, or an alibi through a scapegoat in case of failure! It was a perfect strategy. They could loudly proclaim later that the Muslim vote did not come to the Congress after the demolition of the Babri masjid solely because of me. It remains to be seen whether the future will vindicate me in this regard” (p 188). For a lay reader, these political manoeuvrings and games of one-upmanship are difficult to fathom. Rao could have guided the reader through this maze by bringing out the political confabulations, their nuances and his political compulsions but he has preferred to remain silent for ever as a true Congressman! By indulging in legalistic sophistry rather than recording what actually happened behind the scenes, he has wasted the valuable opportunity to clear his name.

Lessons for the FutureLessons for the FutureLessons for the FutureLessons for the FutureLessons for the Future

We shall now turn to the lessons for the future. The main question is whether the Constitution needs to be amended in any way as advocated by Rao. While Rao presumably wanted to have the emergency powers of the centre enlarged, states are

Economic and Political Weekly May 27, 2006 keen on their curtailment. The Sarkaria Commission and the Commission to Review the Working of the Constitution have, on the contrary, recommended certain precautionary measures to prevent the misuse of these articles by the centre [Kashyap 2004]. But, clearly, no one had visualised that the country will be faced with a situation, as in UP, in which a recalcitrant state government, belonging to a major national party, would be bent on flouting all constitutional norms and proprieties, and disregarding the unequivocal commitments given by it to the central government, the national integration council, the high court and the Supreme Court. Similar eventualities cannot be ruled out in the future and the centre’s discretion under the emergency provisions must not be circumscribed in any way. After the stringent safeguards of judicial review laid down by the Supreme Court in Bommai case, there need be no fears of misuse of these powers by the centre.

Austin has presented an alarmist and exaggerated assessment of rapidly expanding CPMFs and the fears of central intervention generated thereby among states [Austin op cit:599-600]. It is important to note that except for the central reserve police force, all other central forces have been created for specific purposes such as border guarding, protection of railways and central industrial and other establishments, etc, and are diverted and deployed in aid of civil power only when inescapable. While the centre is urging the states to augment their police strength and reduce their dependence on central forces, it is the states which have been clamouring for support of CPMFs. In spite of the wide discretion given to the centre by Article 355, this power was used by the centre only once in 1968 in Assam, West Bengal and Kerala and that too only to give protection to the central government offices and the central public sector undertakings. Though the CPMFs and armed forces have been stationed in various parts of the country, they have not been deployed by the centre on its own at any time to contain “internal disturbance”. Invariably, the CPMFs have been placed at the disposal of the state governments whenever requested by them. During such deployment, they operate only under the control of the state government.

It is difficult to believe but though Article 257A was repealed by the 44th Amendment, even the National Democratic Alliance (NDA) government wanted its provisions to be reintroduced! The group of ministers on reforming the national security system had recommended that a supporting legislation, in pursuance of Article 355, may be passed by Parliament to provide for: “(a) Suo moto deployment of central forces, if the situation prevailing in the states so demands; (b) Defining powers, jurisdiction, privileges and liabilities of the members of the central forces while deployed in states in accordance with Entry 2-A of the Union List; and

(c) Specifying situations construed as failures/break-down of constitutional machinery in a state in which the central government can intervene to advise or direct, as the case may be, a state government and violation of these advisories/ directions would invite action under Article 365/352” [GoI 2001]. It is often said that public memory is short. But, even the BJP had conveniently forgotten its own postures and threats during the critical period in November-December 1992 when it had stoutly opposed the central government taking recourse to Articles 355 and 356 in UP.

A reference may be made to the critique of the Bommai judgment by Soli Sorabjee. As he has rightly stated, the decision of the Supreme Court will go a long way in minimising the centre’s frequent onslaught on states, but some of the observations of the judges made in the course of arriving at the conclusions are of serious concern. According to justices Jeevan Reddy and Agrawal, “if a political party espousing a particular religion comes to power, that religion tends to become, in practice, the official religion. All other religions come to acquire a secondary status, at any rate, a less favourable position.” They further held that “under our Constitution, no party or organisation can simultaneously be a political and a religious party. It has to be either”. There is no dissent or qualification or reservation by any of the other judges on this part of the judgment. Accordingly, the legal position enumerated by justices Jeevan Reddy and Agrawal can be regarded as the law laid down by the apex court. It is impossible to describe them as obiter dicta. Sorabjee has rightly stated that “these propositions are over-broadly stated” (Journal section (1994) 3 SCC, p 30). The law laid down by the apex court is questionable and is bound to become a mine-field though it has escaped public attention so far.

The final chapter in the history of this momentous event will unfold when the Liberhan Commission submits its report. But, the painful memories of the demolition of the Babri masjid, which signified a monumental failure of governance of the country, will linger for a long time. Making Constitution the scapegoat, as Rao has tried to do, will not take us anywhere. This national tragedy calls for sincere introspection on the part of all political parties, the civil society and all those who have the interest of the country at heart. The tragedy showed how fragile the Constitution can be in such crisis situations. It highlighted the weaknesses of the major pillars of democracy. But, this was due to the failure of political leadership at various levels. Almost all those responsible, in one way or another, for the tragedy have got away. The foremost of them was Kalyan Singh who incredibly got away with only a token punishment of one day’s imprisonment and a fine of Rs 2,000 for contempt of the highest court of the country!




1 Legally speaking, president’s rule is not imposed by the president of India, but by the central government with the approval of the president.

2 S R. Bommai vs Union of India and Others

(1994) 3 SCC, p 9. 3 Ibid, p 11. 4 Ibid, pp 380-81.


Gill, S S (1996):The Dynasty: A Political Biography of the Premier Ruling Family of Modern India, Harper Collins India, pp 416-17.

Godbole, Madhav (1996): Unfinished Innings: Recollections and Reflections of a Civil Servant, Orient Longman, New Delhi.

GoI (1988): Report of the Commission on Centre-State Relations, Part I, Government of India, pp 165-69.

– (2001): Recommendations of the Group of Ministers on Reforming the National Security System, Government of India, February, p 43.

Granville, Austin (1999): Working a Democratic Constitution: The Indian Experience, Oxford University Press, New Delhi.

Jain, M P (2005): Indian Constitutional Law, fifth edition, Wadhwa and Company, Nagpur, p 682.

Kashyap, S C (2004): ‘Report of the National Commission to Review the Working of the Constitution’ in S C Kashyap, Constitution Making since 1950: An Overview, Universal Law Publishing Company, New Delhi, pp 421-27.

Noorani, A G (2000): Constitutional Questions in India, Oxford University Press, New Delhi, p 272.

Economic and Political Weekly May 27, 2006

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